522022 LIST OF GOODS PRODUCED BY CHILD LABOR OR FORCED LABOR
How China's Forced Labor Impacts Solar
Supply Chains Worldwide
Polysilicon is a key input in the production of solar
modules, and nearly half of the world's solar-grade
polysilicon comes from Xinjiang, a region in western
China. Polysilicon is used by some of the biggest
solar companies in China to produce photovoltaic
ingots and photovoltaic wafers, which become solar
cells and panels. By U.S. Department of Energy
estimates, Chinese companies own over 75 percent
of global capacity for manufacturing wafers, cells,
and modules. Along with the practice of mixing
polysilicon from different sources, it is highly likely
that polysilicon from Xinjiang ends up in solar
products produced in China.
This is a problem because of China's state-sponsored
forced labor and human rights abuses against over
one million Uyghurs and Muslim minorities in
Xinjiang and in other parts of China. (36) Many of
these solar products containing inputs produced
with forced labor are used domestically in China.
However, China's leading role in solar supply chains
raises forced labor risks for any business importing
solar products, which, absent extensive due diligence,
have a high likelihood of containing inputs made
with forced labor in China. Some of these products
may enter the U.S. directly from China: in 2020, the
U.S. imported about 5 percent of its solar cells and
modules from China. In addition, without careful
due diligence, companies may be at risk of importing
goods with inputs made with forced labor into
the U.S. from third countries. In 2020, countries
imported over $24 billion in solar cells and modules
from China, representing 42 percent of all solar
module imports worldwide and including some of
the U.S.'s biggest solar trade partners. Meanwhile,
Chinese solar companies own or have subsidiaries
around the world, and some of them are directly
linked with Xinjiang's forced labor program. ILAB's
research indicates that further downstream silica-
based products, including additional solar products
and semi-conductors, may be at risk. Read more
about the various products at risk in Figure 14
The Uyghur Forced Labor Prevention Act (UFLPA),
signed into law in December 2021, establishes a
rebuttable presumption that goods made wholly or
in part in Xinjiang, or produced by certain entities
included on the UFLPA Entity List, are made with
forced labor. Based on this presumption, these goods
are subject to the import prohibition under Section
307 of the Tariff Act, which prohibits the import of
goods made wholly or in part with forced labor. The
law specifically names polysilicon as a high-priority
sector for enforcement. The Department of Labor's
reporting, tools, resources, and expertise inform
the UFLPA's strategy and are valuable resources for
companies to safeguard their solar supply chains
from forced labor. Learn more about how polysilicon
from Xinjiang may find its way into solar supply
chains globally in Figure 15.
Pages 52 and 53.
https://www.dol.gov/sites/dolgov/fi...ports/tda2021/2022-TVPRA-List-of-Goods-v3.pdf